Colony Collapse Disorder, or CCD, "is the name
given to the mysterious decline of honeybee populations around the world
beginning around 2006." Since that time, "one-third of the U.S. honeybee
population has died off or disappeared (more than twice what is normal).

The document...reveals that EPA scientists have
essentially rejected the findings of a study conducted on behalf of Bayer that
the agency had used to justify the registration of clothianidin.

Clothianidin imperils the health of the nation's honeybees' says a Colorado
beekeeper, the recipient of the document.

If the Environmental Protection Agency had evidence that a specific pesticide
might be at least in part responsible for Colony Collapse Disorder, a dreadful
syndrome named for the devastation of the bee population, you would expect the
agency to act on that information. Perhaps it would propose banning the
offensive substance outright or, at a minimum, suspend its use until more facts
were gathered. However, according to Colorado beekeeper Tom Theobald, the EPA is
doing just the opposite; upgrading the pesticide's classification and continuing
to make it available.

Colony Collapse Disorder has nothing to do with the collapse of the Greek
Empire, or the sun actually setting on the British Empire, or even with the
colonization of the New World. According to the Pesticide Action Network
(http://www.panna.org/), Colony Collapse Disorder, or CCD, "is the name given to
the mysterious decline of honeybee populations around the world beginning around
2006." Since that time, "one-third of the U.S. honeybee population has died off
or disappeared (more than twice what is normal)."

And while it is unclear exactly what has caused this serious problem, "a
range of evidence points to sub-lethal pesticide exposure": "Neonicotinoids are
a particularly suspect class of insecticides; so much so that Italy and France
have banned or restricted their use to protect their honeybee populations. This
class of insecticides is highly neurotoxic to bees, and works by disabling
insects' immune and nervous systems."

Tom Philpott, a senior food and agriculture writer for Grist, an online
environmental magazine, recently pointed out that a leaked document (nothing to
do with Julian Assange's WikiLeaks) "involves the German agrichemical giant
Bayer; a pesticidewith an unpronounceable name, clothianidin; and an insect
species crucial to food production (as well as a food producer itself), the
honeybee." This leaked document, was delivered to Tom Theobald, a long-time
Colorado beekeeper.

Philpott pointed out that a recently released internal EPA memo "confirms
that the very agency charged with protecting the environment is ignoring the
warnings of its own scientists about clothianidin, a pesticide from which Bayer
racked up €183 million (about $262 million) in sales in 2009.

"Clothianidin has been widely used on corn, the largest U.S. crop, since
2003. Suppliers sell seeds pre-treated with it. Like other members of the
neonicotinoid family of pesticides, clothianidin gets 'taken up by a plant's
vascular system and expressed through pollen and nectar,' according to Pesticide
Action Network of North America (PANNA), which leaked the document along with
Beyond Pesticides. That effect makes it highly toxic to a crop's pests -- and
also harmful to pollen-hoarding honeybees, which have experienced mysterious
annual massive die-offs (known as 'colony collapse disorder') here in the United
States at least since 2006."

According to Philpott, the document, leaked to Tom Theobald, reveals that EPA
scientists have essentially rejected the findings of a study conducted on behalf
of Bayer that the agency had used to justify the registration of clothianidin.
And they reiterated concerns that widespread use of clothianidin imperils the
health of the nation's honeybees." ?

Despite this conclusion, Philpott reported, an EPA "spokesperson, who asked
not to be named but who communicated on the record on behalf of the agency,
replied that clothianidin would retain its registration and be available for use
in the spring."

Part of the explanation for the EPA's apparent inaction on the pesticide
stems from the fact that all this started back during the Bush Administration.
It also may be that a recent New York Times article headlined "Scientists and
Soldiers Solve a Bee Mystery," reported that "A fungus tag-teaming with a virus
have apparently interacted to cause the [bee] problem, according to a paper by
Army scientists in Maryland and bee experts in Montana in the online science
journal PLoS One."

It may also be that the agency -- as it is currently constructed -- which has
been under attack from a number of conservative organizations, as well as the
U.S. Chamber of Commerce, isn't quite up to the task of taking on a huge
petro-chemical company like Bayer.

"In the EPA's dealings with Bayer on this particular insecticide," Philpott
noted, "the agency charged with protecting the environment has consistently made
industry-friendly decisions that contradict the conclusions of its own
scientists -- and threaten to do monumental harm to our food system by wiping
out its key pollinators."

In a radio interview, Colorado beekeeper Tom Theobald called pesticides the
"elephant in the room that's not being talked about": "Pesticides are the
portion of this problem that can be most immediately addressed without any new
money, any new people, any new laws.... If we don't solve this pesticide
problem, these other things aren't going to matter. We're going to have some of
the best-looking cadavers that we've had in years."

In early October, the New York Times ran a piece titled "Scientists and
Soldiers Solve a Bee Mystery" that reported that "A fungus tag-teaming with a
virus have apparently interacted to cause the problem, according to a paper by
Army scientists in Maryland and bee experts in Montana in the online science
journal PLoS One."

The Pesticide Action Network recently pointed out that, "At issue in the NYT
piece is the conspicuous absence of pesticides as a causal factor in the
purported 'solving' of CCD (a 'fungus tag-teaming with a virus'). As Katherine
Eban of CNN Money points out, 'What the Times article did not explore - nor did
the study disclose - was the relationship between the study's lead author,
Montana bee researcher Dr. Jerry Bromenshenk, and Bayer Crop Science. In recent
years Bromenshenk has received a significant research grant from Bayer to study
bee pollination.'"

According to the PAN, Theobald "lamented the [New York Times'] article's
over-reach, noting that the newly discovered virus is simply co-present with CCD
and that correlation does not mean causation. Many scientists and beekeepers
believe that sub-lethal pesticide exposure weakens bees immune and nervous
systems, rendering them susceptible to the increase in disease and apparent
decrease in navigational abilities that are the hallmark symptoms of CCD."

Philpott pointed out that on April 22, "the EPA finally ended clothianidin's
long period of 'conditional' purgatory -- by granting it full registration. The
agency gifted the bee-killing pesticide with its new status quietly; to my
knowledge, the only public acknowledgment of it came through the efforts of
Theobald, who is extremely worried about the fate of his own bee-keeping
business in Colorado's corn country."

The leaked memo dated November 2, stated: "Clothianidin's major risk concern
is to nontarget insects (that is, honey bees). ...? Acute toxicity studies to
honey bees show that clothianidin is highly toxic on both a contact and an oral
basis. Although EFED does not conduct ... risk assessments on non-target
insects, information from standard tests and field studies, as well as incident
reports involving other neonicotinoids insecticides (e.g., imidacloprid) suggest
the potential for long term toxic risk to honey bees and other beneficial
insects."

According to Philpott, "The real kicker is that the researchers essentially
invalidated the Bayer-funded study -- i.e., the study on which the EPA based
clothianidin's registration as an fully registered chemical. Referring to the
pesticide, the authors write: 'A previous field study [i.e., the Bayer study]
investigated the effects of clothianidin on whole hive parameters and was
classified as acceptable. However, after another review of this field study in
light of additional information, deficiencies were identified that render the
study supplemental. It does not satisfy the guideline 850.3040, and another
field study is needed to evaluate the effects of clothianidin on bees through
contaminated pollen and nectar. Exposure through contaminated pollen and nectar
and potential toxic effects therefore remain an uncertainty for pollinators.'"

Jay Feldman of Beyond Pesticides told Philpott that he found "the EPA
response either misinformed or misleading. The paper trail on this is clear.
We're talking about a bad study required by EPA [that is central] to the
registration of this chemical."

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